Discussion # 1

Your client was notified by the IRS that he owes $50,000 in back taxes.  In an effort to resolve the dispute you helped him go through the IRS appeals process ….  Unfortunately, you were not successful.  Thus, you  are now prepared to  go to  court and  you have two options  (1)   TAX COURT (2)   DISTRICT COURT.  If you were to write a letter to your client, what advantages and disadvantages of each of these options would you list?

Discussion #2

Where are regular Tax Court decisions published?  Illustrate the elements of both a temporary and a permanent regular Tax Court citation.  Explain what each part of the citation means.